2026 (7) TMI 1173

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.... the Respondents: Mr Fenil Bhatt, i/b. Mr. Atul K. Jasani,. ORDER (PER: ADVAIT M. SETHNA, J) :- 1. These Appeals are filed under Section 260-A of the Income Tax Act, 1961. It assails the common judgment and order passed by the Income Tax Appellate Tribunal, 'E-Bench', Mumbai ("ITAT" for short) in Income Tax Appeal 3226/M/2017 & Ors. (for short "Impugned Order"). The Appeal No. 2793 of 201....

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.... incriminating material, in the assessment year where the original assessment was unabated? 4. Mr. Sharma, learned counsel for the Appellant in the course of his arguments would fairly submit that the legal issue formulated through the substantial question of law arose for consideration before the Supreme Court in Principal Commissioner of Income Tax, Central -3 Vs. Abhisar Buildwell (P) Ltd. [....

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....ncome which is found during the course of search or pursuant to requisition. Therefore, only in a case where undisclosed income is found on the basis of incriminating material, the Assessing Officer would assume jurisdiction to assess or reassess the total income even in the case of completed/unabated assessment. 7. Mr. Fenil Bhatt, learned counsel for the Respondent would submit that the subst....